FAQs: Uniform Closing Dataset
July 26, 2022 Updates
Loan Delivery Q7, UCD Critical Edits Q11, Q13, Qualified Mortgages Q29
The following provides answers to questions frequently asked about Fannie Mae’s and Freddie Mac’s (GSEs’) jointly developed Uniform Closing Dataset (UCD). The GSEs developed the UCD at the direction of the Federal Housing Finance Agency (FHFA) as part of the Uniform Mortgage Data Program® (UMDP®), an ongoing initiative to enhance loan quality and consistency through uniform loan data standards for the single-family loans the GSEs purchase.
1. What is the UCD?
The UCD is a common industry dataset allowing information on the Consumer Financial Protection Bureau’s (CFPB’s) Closing Disclosure to be communicated electronically.
The GSEs are collecting UCD data because it:
- Helps enhance credit risk management with more data and better-quality data.
- Provides important information to help increase our ability to detect fraud and misrepresentation at loan delivery.
- Provides additional transparency into the mortgage loan transaction file to help assess whether the loan, as closed, meets the GSE’s eligibility requirements.
2. Are lenders required to deliver the UCD?
Yes. A UCD XML file (including the associated embedded PDF) must be submitted to the purchasing GSE’s UCD collection solution prior to loan delivery. Each GSE’s respective loan delivery system checks for a successful UCD submission for all loans with a Note Date on or after September 25, 2017.
3. How do the GSEs collect the UCD?
The GSEs have separate collection solutions for lenders and technology solution providers to submit their UCD XML files. Support and training resources related to each unique collection solution are available on each GSE’s respective UCD pages.
4. What is required to be delivered to each GSE’s UCD collection solution?
The following must be included for all loans delivered to the GSEs:
- The UCD in XML file format with the embedded Closing Disclosure PDF. Loans submitted to a GSE’s Selling/Loan Delivery solutions without a corresponding UCD XML file containing an embedded Closing Disclosure PDF will receive a fatal/critical edit and are not eligible for purchase.
- Data provided in the UCD XML file must match the data on the PDF of the Closing Disclosure.
- These requirements include loans not subject to the CFPB’s TILA-RESPA Integrated Disclosure (TRID) rule.
You do not need to include:
- Signatures on the Closing Disclosure or any associated addendum. Lenders may wish to continue current industry best practices of obtaining interested party signatures in accordance with the signature requirements of the TRID rule.
5. How do the GSEs identify which delivered loans are required to have a UCD file?
The GSEs use the Note Date reported in the loan delivery XML file to determine if the loan is required to have a corresponding UCD file. The UCD is required for all loans with a Note Date that is on or after September 25, 2017.
6. Will the UCD Delivery Specification continue to be the same for both GSEs?
Yes. Although the GSEs have implemented separate UCD collection solutions, both GSEs adhere to the guiding principles established under the UMDP and are using the identical UCD Delivery Specification containing the same data points, enumerations, and conditionalities.
7. When will the GSEs begin accepting UCD submissions with “Enact” identified as the Mortgage Insurance (MI) Company?
The UCD specification has been updated to add “Enact” as a valid value for MICompanyNameTypeOtherDescription (UID 3.029). This change became effective for Enact-insured loans delivered to Fannie Mae on and after February 17, 2022, and for Enact-insured loans delivered to Freddie Mac on and after February 11, 2022.
Currently, both GSEs continue to accept the value “Genworth” in the UCD xml file; however, on June 27, 2022 (Fannie Mae) and August 1, 2022 (Freddie Mac), will begin to return warning messages when a value of “Genworth” is included.
8. What is the UCD Critical Edits transition?
The GSEs are converting certain data edits in their UCD collection solutions from “warning” to “critical.” The two-year rollout approach is occurring over four phases, with each phase addressing data points that closely align with given sections of the Closing Disclosure. The transition is designed to enhance data quality and consistency for the single-family loans we purchase.
The UCD Critical Edits Phase 2 transition was implemented on March 31, 2022.
9. What is the implementation timing for the remaining Phases?
The GSEs revised the implementation dates for Phase 3-4.
|Phase 3||May 1, 2023|
|Phase 4||November 6, 2023|
10. Can we implement the remaining phases before the actual date?
The GSEs encourage you to complete transition activities ahead of schedule to ensure your organization’s readiness in advance of each phase.
11. Is there a new UCD datapoint?
Refer to the revised July 26 UCD Specification Impact Memo for the requirements of a new data point to capture the annual percentage rate (APR) for adjustable-rate mortgages (ARMs) with interest rate changes within the first five years. The new data point is gse:QualifiedMortgageShortResetARM_APRPercent.
Note: This datapoint will be required for all ARMs meeting the definition on and after May 1, 2023.
12. How do we prepare for the UCD Critical Edits?
- UCD Critical Edits Matrix − contains the edits and associated datapoints for all phases.
- UCD Critical Edits Implementation Guide − provides guidance on the transition to these specific edits. Portions of the Closing Disclosure are used throughout the guide to illustrate data elements identified as “critical” by highlighting those in bold font.
- Customer test environments − Each GSE will provide opportunities for lenders to test their UCD XML files to resolve potential critical issues prior to the phased releases.
- Critical edits feedback message codes and text − Each GSE publishes a list of feedback messages for each phase of the UCD Critical Edits for their respective UCD collection solutions.
13. How do I find how critical edits differ from the UCD Specifications (Appendix I)?
The UCD Critical Edits Matrix includes column Difference Between Specification and the Critical Edit which indicates the differences. The July 26 UCD Specification Impact Memo lists differences between the UCD Critical Edits Matrix and the UCD Specification.
14. How do we use the UCD Critical Edits Matrix?
The document contains data points and associated data points categorized by implementation phases. The critical edits in each phase are organized in CD Form Field ID order. Any GSE-specific data point edits are provided at the end in UCD XML order.
Review the UCD Critical Edits Matrix tabs which include the following:
- Front Cover – date and version
- Revision Log - changes by phase, type of change and change description.
- Read Me – details on global changes
- Column Descriptions – provides corresponding letter, column name and description
15. What happens if I do not comply with the Post-Loan Delivery – Best Practice Guidelines? When are they going to be made effective?
The UCD Resubmission Best Practice Guidelines do not have an effective date. The GSEs view these guidelines as generally accepted practices that should have been followed since the initial UCD mandate. The guidelines are not an enforceable policy. There are no plans to enact critical / fatal messaging to its affect.
16. What happens if my loan is selected for post-purchase review and I have not submitted the most recent closing disclosure to the GSE collection solution?
The UCD Resubmission Post-Loan Delivery Best Practice Guidelines do not replace or modify the current GSEs requirement that the final Closing Disclosure be included in the loan file and made available for a post-purchase review.
17. Do the GSEs provide a testing environment for lenders and vendors?
18. Do the GSEs provide validation that a lender’s or vendor’s XML file formation is correct?
Yes, each GSE validates the UCD XML file formation against the MISMO v3.3.0 Reference Model schema upon delivery. In addition, each GSE provides the industry with sufficient notice regarding its implementation and enforcement of any business rule messaging.
19. Is the Seller data (and the Seller’s Closing Disclosure PDF) required as part of the UCD XML file submission?
As of June 24, 2019, lenders are required to include the seller data as indicated in the industry announcement. For further guidance, refer to the UCD Delivery Specification version 1.5 which includes these seller data updates. No new data has been added to the UCD Delivery Specification v.1.5, nor have elements been removed.
20. If after closing, but before delivery of loans to the GSEs, information on the Closing Disclosure was updated and a revised Closing Disclosure was provided to the borrower, which version of the Closing Disclosure and UCD should I submit to the GSEs?
The GSEs require that the submitted Closing Disclosure and UCD XML file represent the most accurate agreed-upon terms of the loan at time of loan delivery to the GSEs.
21. Do the GSEs require a first-generation PDF of the Closing Disclosure be embedded in the UCD XML file?
No, the GSEs only require that a clear and legible PDF of the Closing Disclosure be embedded in the UCD XML file reflecting the data submitted within the UCD XML submission.
22. We issue a separate Closing Disclosure to each borrower (e.g., if there are three borrowers, we produce three separate Closing Disclosures). Do the GSEs require the Closing Disclosure for each borrower be included in the UCD XML file?
No. In instances where the lender has issued a separate Closing Disclosure for each borrower, the lender should embed only one representative copy of the Closing Disclosure in the XML file.
23. If the transaction involves a simultaneous second (e.g., an 80/10/10 transaction), do the GSEs require delivery of the Closing Disclosure for the simultaneous second even if they are not purchasing the second lien?
No. At this time, neither GSE collects the separate Closing Disclosure for any simultaneous second that is part of the transaction. The GSEs require delivery of the Closing Disclosure only for the loan being purchased.
24. What is the CurrentRateSetDate and where is it found?
In the UCD specification, the CurrentRateSetDate is the last date that the note rate on a loan was established. This includes the first time the rate is set as well as any time the rate was changed prior to closing.
Note: that this does NOT include any action to extend a lock period, since the rate does not change for just an extension. The CurrentRateSetDate is used to evaluate the Note Rate, and therefore, it must correspond to the date on which the rate was set.
25. Where can I find the Average Prime Offer Rates (APOR)?
Refer to https://ffiec.cfpb.gov/tools/rate-spread for information on how to calculate the APOR.
26. How can I reflect a principal curtailment for a refinance on the Alternate form?
In instances where a principal curtailment is needed to reduce the cash back to the borrower, it is allowable to reflect the principal curtailment (principal reduction) in the Payoffs and Payments table on the Alternate form. See Appendix F: UCD Sample Use Case NonSeller ARM 5yrIO for an example.
27. How can I reflect gifts and grants on the Alternate form?
If a refinance transaction includes a gift or grant which reduces the monies the borrower must bring to closing, it is allowable to reflect the gift or grant as a (-) negative value in the Payoffs and Payments table on the Alternate form. See Appendix F: UCD Sample Use Case NonSeller ARM 5yrIO for an example.
28. How can I reflect a simultaneous second loan on the Alternate form for a refinance?
Per the Regulation, each closed-end loan in the transaction must have its own Closing Disclosure. Currently, second loans closing simultaneously are not reflected on the Alternate Closing Disclosure form of the first lien. For more information regarding how to handle simultaneous second loans on the Alternate form, refer to the CFPB’s October 1, 2014, recorded webinar entitled, “FAQs on the TILA-RESPA Integrated Disclosures Rule, Part 3 – Completing the Loan Estimate” and the “Index of TRID Questions Addressed During Webinars.” These can be found on the Federal Reserve System’s Consumer Compliance Outlook website.
29. Were there additional Qualified Mortgage (QM) data quality updates added to the existing Phase 1 critical edits?
Yes, the GSEs determined there was a need to include additional data quality updates for QM data points that were not required by the v1.5 UCD Specification. See the revised July 26 UCD Specification Impact Memo.
30. If a loan is considered Exempt from Regulation Z’s Ability to Repay (ATR) requirements, how should a UCD XML file be submitted?
The file should be submitted in UCD with the following data points if the loan is classified as Exempt:
- AbilityToRepayExemptionReasonType=PropertyUsage or LoanProgram
Note: Use PropertyUsage for investment properties, use LoanProgram for Housing Finance Agency (HFA).
31. Is the UCD specification impacted by the transition from the London Interbank Offered Rate (LIBOR) to the Secured Overnight Financing Rate (SOFR)?
Updates to the UCD specification are not necessary to support the transition from LIBOR to SOFR.
32. How do I include SOFR as the IndexType with no UCD specification updates being made?
SOFR should be designated as the IndexType using IndexType = Other and IndexTypeOtherDescription = SOFR as indicated in the table below.
|UCD Datapoint||UCD Unique ID||Delivery Details|
This follows the same principle used today for LIBOR; MISMOIndexType data point specifies the general category of the mortgage index (LIBOR) instead of the precise index (MISMO Index Source Type (e.g. LIBOROneYearWSJDaily).
Note: If your business process requires delivery of ‘30DayAverageSOFR’, this value can be delivered in the UCD instead of ‘SOFR’ and will not impact the status of your UCD submission or the eligibility of the loan.
33. Do the GSEs require a Closing Disclosure to be delivered for construction loans?
The GSEs only purchase construction loans at the permanent financing phase of the transaction. The GSEs expect that the Closing Disclosure and UCD XML be delivered prior to loan purchase only if the TILA / RESPA Integrated Disclosure Rule requires that a Closing Disclosure be issued to the borrower.
34. Which Closing Disclosure is required for a Construction to Permanent loan, the original or a new Closing Disclosure?
For a single-close (without an executed modification) or a two-close, the latest Closing Disclosure that discloses the terms of the permanent financing must be included in the UCD file submission. If a modification has been completed prior to permanent financing, the terms of the loan modification become the permanent financing and therefore, an updated Closing Disclosure is not required.
Note: As of March 1, 2022, single-closing construction-to-permanent loans must meet QM requirements and may require an update to the UCD submission if a modification impacts QM data points (i.e., APR, Average Prime Offer Rate, Note Amount, etc.).
35. How are Construction loans classified?
For properties where the borrower does not own the land prior to closing of interim construction financing, the loan is classified as a Purchase transaction. If the borrower already owns the land, the loan is classified as a Non-Seller (refinance) transaction.
36. For construction loans where the subject property address does not have a street address, is the Legal Description acceptable?
Yes, the legal description is acceptable; however, the subject property Zip Code is required.
37. How should I handle negative values in the UCD XML file? For example, should the Aggregate Adjustment value in the Closing Costs Details section of the Closing Disclosure be submitted as a negative value in the XML file?
Any value that is reflected as a negative value on the Closing Disclosure should be carried as a negative value in the UCD XML. In the limited situations where a value appears on the Closing Disclosure in two places – once as a positive value and once as a negative value (e.g., L. Paid Already by or on Behalf of Borrower at Closing) then submit that value as a positive number in the UCD XML.
Note: Some values appear twice on the Closing Disclosure but the values are conveyed using different data points (e.g., Seller Credits in the Calculating Cash to Close table and Seller Credits in the Summaries of Transaction). In those instances, submit the value using the appropriate data point for each section and include a (-) negative sign if it is reflected as a negative value on the Closing Disclosure.
38. I have run my loan through both Desktop Underwriter® (DU®) and Loan Product Advisor® and received an AutomatedUnderwritingCaseIdentifier from both systems. For ease, can I include the AutomatedUnderwritingCaseIdentifier and AutomatedUnderwritingSystemType for both DU and Loan Product Advisor in the UCD XML file just as I do for appraisals?
Yes. You may include an instance of AutomatedUnderwritingCaseIdentifier and AutomatedUnderwritingSystemType for both Desktop Underwriter and Loan Product Advisor in the UCD XML file if this facilitates your UCD and loan delivery process.
39. The UCD contains several Ability-to-Repay (ATR) data points marked as “GSE Requirement” in Appendix I. Do these data points need to be included in the UCD delivery file?
Yes, the data points designated as “GSE Requirement” in Appendix I must be included in the UCD XML file per the defined conditionality. This requirement will be enforced for all loan types whether the loan is for a primary residence, second home, or an investment property.
40. My loan transaction includes a Buydown but the Buydown does not fall within the CFPB’s requirements for being reflected on the Closing Disclosure. How should I indicate this in the UCD XML file?
When a loan has a buydown that is not required to be reflected on the Closing Disclosure, the value for the data point BuydownTemporarySubsidyFundingIndicator must be “true” and the value for the data point BuydownReflectedInNoteIndicator must be “false.”
41. My UCD XML files include extra data that is not included in Appendix I: UCD Delivery Specification. Do the GSEs ignore “extra” data in the UCD XML files?
No. The UCD XML files delivered to the GSEs must contain only the data specified in Appendix I: UCD Delivery Specification. Additionally, any data points or structures that are not relevant to the closing transaction (and therefore would be blank on the Closing Disclosure) should not be sent in the XML file.
42. After settlement, we found that we must make some corrections to the Closing Disclosure and redisclose to the borrower. Because this updated Closing Disclosure will not have borrower signatures, how should I redeliver the signature-related data points?
In instances where the UCD is redelivered after settlement and the Closing Disclosure does not have a signature, the following signature-related data points should be delivered with the following values:
- Document Signature Required Indicator = ”false”
- Actual Signature Type – not applicable (not redelivered)
- Execution Date – not applicable (not redelivered)
43. What is the DisplayLabelText attribute?
The DisplayLabelText attribute allows free-form text and is used for the purpose of representation of the UCD supported enumerations, in a more readable format, as it would be displayed on the form. For example, a DisplayLabelText value may read as “Attorney Doc Prep Fee,” which would be the actual verbiage on the form. A corresponding enumerated value of “DocumentPreparationFee” would also be populated in the XML along with the DisplayLabelText.
Sample XML Snippet:
Sample Form Snippet:
44. What is the purpose of the IdentifierOwnerURI attribute?
The IdentifierOwnerURI is a URL intended to contain the web address for the organization that is responsible for (or issues) the corresponding identifier and is used to help recognize “bad actors” in the industry. For example, the AppraisalIdentifier, or Doc File ID, is issued by the Uniform Collateral Data Portal®; therefore, the IdentifierOwnerURI for the AppraisalIdentifier would be “https://www.uniformdataportal.com/VAMAuthUtility/login.aspx”. Another example is the IdentifierOwnerURI that supports the LicenseIdentifier in the Contact Information section of the Closing Disclosure Form. A lender will have a federal license that is issued and maintained by the Nationwide Multistate Licensing System & Registry. As a result, the IdentifierOwnerURI for a lender’s license would be “mortgage.nationwidelicensingsystem.org”.
Sample XML Snippet 1
Sample XML Snippet 2
The GSEs expect “best effort” in obtaining this data.
45. Should specific fees (e.g., Recording fees, Transfer tax fees, etc.) be lumped into one total or itemized? For the cases where fees cannot be mapped to an exact MISMO value, should ‘Other’ and appropriate description be used for the enumerations not supported in the UCD?
Both GSEs strongly advise using the provided enumerated fees in each section of the UCD, as defined in the MISMO Logical Data Dictionary, to minimize the use of “Other” and provide the borrower with as much detail as is practical and remain in compliance with the TRID regulation. The decision to bundle or individually itemize various Recording fees and Transfer taxes is up to the lender’s interpretation of the TRID Regulation subsection 1026.37(g)(1). The UCD Specification simply provides the data structures to transmit the information in accordance with a lender’s interpretation.
46. Is it OK to deliver a data point using the “Other” enumeration in conjunction with “TypeOtherDescription”?
If a valid enumeration exists in the UCD for the item being represented on the closing disclosure form, then that enumeration must be used. For example, “RealEstateCommissionsSellersBroker” and “RealEstateCommissionsBuyersBroker” must be delivered as a FeeType instead of using “Other” and FeeTypeOtherDescription.
47. Are resources available to help me implement the UCD?
The GSEs have published a number of implementation materials and artifacts on their respective Fanniemae.com and Freddiemac.com websites to assist you with your UCD implementation. These materials include:
- Appendix C: Closing Disclosure with Reference Numbers (.pdf)
- Appendix E: UCD Implementation Guide (.pdf)
- Appendix F: UCD Sample Use Cases (.zip)
- Appendix G: UCD Sample XML Files (.zip)
- Appendix I: UCD Delivery Specification (.xls)
Note, these documents are exactly the same for both GSEs.
48. Does Appendix I: UCD Delivery Specification provide mapping only for data that is required on the CFPB’s Closing Disclosure?
No. Appendix I also contains a limited number of additional data points that the GSEs require, beyond the fields present on the CFPB’s Closing Disclosure, as well as data points required to properly form the XML file. The remaining UCD data maps directly to the Closing Disclosure. Additionally, Appendix I include details necessary to create the XML file for delivery to the GSEs. Appendix I is also presented in XML file order providing greater clarity regarding the data that must be delivered according to transaction type (e.g., purchase vs. non-seller/refinance).